Regulatory Information:

Best Execution Policy:

In order to obtain the best possible execution of orders, Massena Partners applies a procedure for selecting and regularly assessing financial intermediaries and counterparties.
As the vast majority of investments initiated by Massena Partners concern Alternative Investment Funds or UCITSs, the company mainly uses the services of its Custodian Account Keepers.
Selection of intermediaries and counterparties is based on the capacity of the organisations considered to correctly execute, settle, record and retain the financial instruments.
The list of authorised intermediaries and counterparties is updated based on an assessment carried out at least one a year and in cases of specific requests for inclusion or withdrawal. Massena Partners reviews its Best Execution Policy at least once a year.


Voting Rights Policy:

The current policy covers measures applicable to voting rights attaching to securities held by the alternative investment funds and UCITSs managed by Massena Partners in order to safeguard investor interests. In addition, the funds have implemented a dedicated policy to respect its commitment to centralise the exercise of voting rights in order to achieve greater efficiency and coherence with regard to shareholder interests.
In accordance with the provisions of the current policy, Massena Partners develops adequate and efficient strategies to determine when and how the voting rights held in the portfolio it manages should be exercised, for the exclusive benefit of clients of Massena Partners and its investors. The strategy defines measures and procedures for:

  • a) monitoring securities transactions;
  • b) ensuring that voting rights are exercised in compliance with the Funds’ objectives and policy;
  • c) the prevention and management of any conflict of interest arising in connection with the exercise of voting rights.


Information about environmental, social and governance criteria (ESG) in the investment policy of Massena Partners:

We inform you that Massena Partners does not currently include any ESG criteria in its investment policy relative to the UCITSs it manages.
Non-financial criteria may, however, be subsequently taken into account to meet new regulatory requirements or new investor expectations.
Massena Partners may manage investment vehicles dedicated to client families; the latter may ask for ESG criteria to be adopted. At present, no fund is concerned.
A brief description of the strategies and details of the measures taken under this policy must be kept at the disposal of investors, and provided free of charge, on request.